Ethical Business Conduct - A Fundamental Expectation from Investors

Investors expect ethical conduct from businesses. They are concerned about loss of management time and resources dealing with such issues, legal liability and damage to reputation due to unethical practices like bribery, corruption, anti-competition and anti-trust. Even though large businesses have formal systems to ensure compliance and avoid unethical businesses, they are exposed to such risks from their supply chains. Corruption and bribery are significant risks to businesses, and they are more pervasive in the supply chain. This makes business functions dealing with suppliers and business partners vulnerable to such risks.

Policy

Our corporation wide Code of Business Conduct (COBC) provides the broad direction for all business transactions. The COBC is Wipro's central and comprehensive compliance policy document that orivides the framework and a common language for ethical conduct for all employees as well as all our stakeholders. The COBC applies to all employees and members of the Board of Directors of the Company, as also to all individuals who serve the Company on contract, subcontract, retainer, consultant or any other such basis. Suppliers, service providers, external professionals, agents, channel partners (dealers, distributors and others) serve as an extension of the Company and their conduct and behavior while carrying out business dealings with Wipro or on behalf of Wipro can have an impact on Wipro and its reputation.

Other than COBC, we also have other policies like the abridged Policy on Related Party Transactions, Wipro Supplier Code of Conduct, Code of Independent Directors and Code of Ethics for Principal Executive Officer and Senior Financial Officers, which contextualize the communication for relevant stakeholders.

Approach

From an anti-bribery compliance perspective, Wipro has the following processes internally to ensure an ethical culture across our business.

A payment due diligence process where payments made by and on behalf of Wipro are reviewed to ensure adherence to anti-corruption and anti-bribery

A Standard Operating Procedure to enable employees understand and comply with the requirements for specific purposes like business courtesies, gifts, entertaining, charitable contribution, sponsorship, etc. Employees are advised to avoid transactions which might give the appearance of offering or accepting an improper payment, bribe or kickback.

Due diligence mechanisms, internal controls and assessments on its third parties such as channel partners, dealers, collection agents, lead finders/hunters etcetera which includes a specific undertaking from identified vendors, service providers, consultants to affirm compliance to our Code of Business Conduct and more specifically to our anti-bribery policies

An Ombudsprocess for receiving and redressing employees’ complaints, through which employees are encouraged to report any fraudulent financial or other information to the stakeholders, any conduct that results in violation of the Company’s COBC (on an anonymous basis, if employees so desire). For more information, refer to Organization Profile

As part of COBC training, Wipro conducts entry-level training to all its employees across levels worldwide on corporate policies pertaining to Business Relationship, Gifts and Entertainment, Business Courtesies and Conflict of Interest. Compliance with Foreign Corrupt Practices Act, UK Bribery Act, the Indian Prevention of Corruption Act, are included as part of leadership training programs and of focused training programs. In addition to annual test and certification of Code of Business Conduct, a certification process is enabled for employees travelling to High Risk Countries and employees working in certain functions. Also, communication of COBC and their significance to Wipro are being done through emails, posters etc.

Compliance

Wipro has a continuing good track of ethical conduct and we comply with all relevant legislations. There has been no significant instances related to bribery, corruption, anti-competitive or anti-trust practices in the reporting period across our business divisions.